Capital Allowances Act 2001 section 270IE

Co-ownership schemes: calculation of allowance after an election

Section 270IE sets out how structures and buildings allowances are calculated and allocated among participants in a co-ownership authorised contractual scheme once an election has been made.

  • The scheme operator calculates allowances by treating the scheme as if it were a single person that owns the relevant property and carries on the qualifying activity
  • Allowances are then allocated to each participant on a just and reasonable basis, with particular regard to the relative size of each participant's unit holdings in the scheme
  • A participant's tax position โ€” including whether or to what extent they are liable to income tax or corporation tax โ€” must not influence the allocation
  • Where participants carry on more than one qualifying activity through the scheme, the calculation and allocation must be performed separately for each activity

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